3    I.  Undisputed Facts  Debtor Casey Jenkins is a salesman by trade.2 In August 2016, he convinced  his sister-in-law, an executive vice president at Edwards Moving & Rigging, to help  him get a job with the company.3 Even though Jenkins’ previous sales experience  was with paper products and janitorial supplies, Edwards, which is in the heavy  hauling, lifting, and rigging business, hired him as a regional sales manager.4  Because Jenkins had no experience in the heavy hauling, lifting, and rigging  industry, Edwards had to provide Jenkins substantial training.5 That training  included safety training; utility safety and on-site training; estimator training;  specifications and capabilities of equipment; pricing; permitting requirements; and  route surveys, including bridge and utility constraints, the need for bucket trucks, and  law enforcement and traffic control.6 On average, it takes an inexperienced    1  The undisputed facts come from factual findings made by United States District Judge Charlene  Edwards Honeywell following a bench trial on Edwards’ breach of contract action against Jenkins in district court. Adv. Doc. No. 8-1. Those findings are attached as Exhibit A to Edwards’ summary judgment motion.Id.Jenkins admits Judge Honeywell’s factual findings as true. Adv. Doc. No. 10 at 2.  2  Adv. Doc. No. 8-1, ¶¶ 4 – 5.  3  Id.at ¶ 5.  4  Id.at ¶¶ 4 – 5.  5  Id.at ¶¶ 5 – 6.  6  Id.at ¶ 6.  Case 8:21-ap-00316-MGW Doc 21 Filed 04/14/22 Page 3 of 13

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